February 15, 1995
Securities & Exchange Commission
450 5th Street, N.W.
Washington, D.C. 20549
Re: Rule 24f-2 Notice for Vanguard Index Trust
File No. 2-56846
Gentlemen:
Pursuant to Rule 24f-2 under the Investment Company Act of 1940, Vanguard
Index Trust (the "Fund"), hereby files its Rule 24f-2 Notice for the fiscal
year ended December 31, 1994. A wire transfer in the amount of $544,105.64
in payment of the registration fee due for the Fund's Rule 24f-2 filing has
been sent to the lockbox at Mellon Bank in Pittsburgh for deposit to the
Securities and Exchange Commission's account number 910-8739.
1. At the beginning of the fiscal year, the Fund had the following
securities registered under the Securities Act of 1933 (the "1933 Act")
other than pursuant to Rule 24f-2, but which remained unsold:
Aggregate Offering
Price of Shares on
which Registration
Name of Securities Number of Shares Fee was Paid
Shares of Beneficial
Interest (No Par Value)
Small Capitalization
Stock Portfolio None None
500 Portfolio None None
Value Portfolio None None
Growth Portfolio None None
Total Stock Market Portfolio None None
Extended Market Portfolio None None
2. During the fiscal year the Fund registered the following securities
under the 1933 Act other than pursuant to Rule 24f-2:
Aggregate Offering
Price of Shares on
which Registration
Name of Securities Number of Shares Fee was Paid
Shares of Beneficial
Interest (No Par Value)
Small Capitalization
Stock Portfolio None None
500 Portfolio None None
Value Portfolio None None
Growth Portfolio None None
Total Stock Market Portfolio None None
Extended Market Portfolio None None
3. The number and the aggregate sales price of the Fund sold during the
fiscal year was as follows:
Name of Securities Number of Shares Aggregate Sales Price
Shares of Beneficial
Interest (No Par Value)
Small Capitalization
Stock Portfolio 11,690,209 $ 184,065,597
500 Portfolio 63,747,713 2,750,911,586
Value Portfolio 19,012,553 220,918,236
Growth Portfolio 5,100,165 51,818,820
Total Stock Market Portfolio 30,585,547 352,146,748
Extended Market Portfolio 11,027,129 213,353,925
Totals 141,163,316 $3,773,214,912
4. The number and aggregate sales price of shares of the Fund sold during
the fiscal year in reliance pursuant to Rule 24f-2 was as follows (See
footnote attached as Exhibit A hereto):
Name of Securities Number of Shares Aggregate Sales Price
Shares of Beneficial
Interest (No Par Value)
Small Capitalization
Stock Portfolio 11,690,209 $ 184,065,597
500 Portfolio 63,747,713 2,750,911,586
Value Portfolio 19,012,553 220,918,236
Growth Portfolio 5,100,165 51,818,820
Total Stock Market Portfolio 30,585,547 352,146,748
Extended Market Portfolio 11,027,129 213,353,925
Totals 141,163,316 $3,773,214,912
Enclosed is an opinion of counsel (Exhibit B) indicating that the
securities sold in reliance upon Rule 24f-2 were legally issued, fully paid
and non-assessable.
Very truly yours,
VANGUARD INDEX TRUST
BY: (Raymond J. Klapinsky)
Secretary
RJK:fms
EXHIBIT "A"
FOOTNOTE TO RULE 24F2 NOTICE OF
VANGUARD INDEX TRUST
The calculation of the registration fee pursuant to subsction (c) of Rule
24f-2 is set forth below. The Fund did not apply any redemptions or
repurchases which took place during the fiscal year to the registration of
any securities pursuant to Section 24(e) of the Investment Company Act.
<TABLE>
<CAPTION>
(a) (b) (c) (d)
Aggregate Sales Aggregate Price of Aggregate Sales Fee Payable
Price of Securities Securities Redeemed Price on which pursuant to
Sold in Reliance or Repurchased fee will be based Section 6(b)
upon Rule 24f-2 During Fiscal Year (a minus b) of 1933 Act
<S> <C> <C> <C> <C>
Vanguard Index Trust
Shares of Beneficial
Interest (No Par VAlue)
Small Capitalization
Stock Portfolio $184,065,597 85,606,436 -- --
500 Portfolio 2,750,911,586 1,753,619,235 -- --
Value Portfolo 220,918,236 109,577,415 -- --
Growth Portfolio 51,818,820 18,266,906 -- --
Total Stock Market Portfolio 352,146,748 76,973,295 -- --
Extended Market Portfolio 213,353,925 151,276,312 -- --
Totals $3,773,214,912 $2,195,319,599 $1,577,895,313 $544,105.64
</TABLE>
EXHIBIT "B"
February 15, 1995
Vanguard Index Trust
1300 Morris Drive, P.O. Box 876
Valley Forge, PA 19482
Gentlemen:
Vanguard Index Trust (the "Fund") is a business trust established under
Pennsylvania law under a Declaration of Trust dated December 31, 1975. I
have acted as legal counsel to the Fund since its initial registration as
an open-end management investment company under the Investment Company Act
of 1940 ("1940 Act"), as amended. It is in my capacity as counsel to the
Fund that I am furnishing you this opinion.
I have examined the Fund's: (1) Declaration of Trust and amendments
thereto; (2) minutes of the meetings of shareholders and Trustees; (3)
Notification of Registration on Form N-8A under the 1940 Act; (4)
Registration Statement on Form N-1A under the Securities Act of 1933 ("1933
Act") and 1940 Act, and all amendments thereto; and (5) all other relevant
documents and records, as well as the procedures and requirements relative
to the issuance and sale of the Fund's shares of beneficial interest
("shares").
Under Article V Section 5.1 of the Declaration of Trust, as amended to
date, the Fund is legally authorized to issue an unlimited number of
shares, without par value, from an unlimited number of series
("Portfolios") of shares. On December 31, 1994, (the end of the Fund's
fiscal year), the Fund had 40,390,090 shares of the Small Capitalization
Stock Portfolio, 217,720,949 shares of the 500 Portfolio, 52,238,008 shares
of the Extended Market Portfolio, 26,697,723 shares of the Value Portfolio,
8,380,378 shares of the Growth Portfolio, and 69,078,582 shares of the Total
Stock Market Portfolio that were issued and outstanding.
My examination also disclosed the following information:
1. On January 1, 1994, (the beginning of the Fund's last fiscal year),
the Fund had no shares registered under the 1933 Act other than pursuant to
Rule 24f-2 of the 1940 Act, but which remained unsold on that date.
2. During the fiscal year ended December 31, 1994, the Fund did not
register any shares under the 1933 Act other than pursuant to Rule 24f-2.
3. During the fiscal year ended December 31, 1994, the Fund sold 11,690
shares at an aggregate sales price of $184,065,597 from the Small
Capitalization Stock Portfolio, 11,027,129 shares at an aggregate sales
price of $213,353,925 from the Extended Market Portfolio; 63,747,713 shares
at an aggregate sales price of $2,750,911,586 from the 500 Portfolio;
19,012,553 shares at aggregate sales price of $220,918,236 from the Value
Portfolio; 5,100,165 shares at an aggregate sales price of $51,818,820 from
the Growth Portfolio; and 30,585,547 shares at an aggregate sales price of
$352,146,748 from the Total Stock Market Portfolio in reliance upon
registration pursuant to Rule 24f-2 of the 1940 Act. During the same fiscal
year, the Fund redeemed 5,550,924 shares at an aggregate redemption price of
$85,606,436 from the Small Capitalization Stock Portfolio, 7,918,343 shares
at an aggregate redemption price of $151,276,312 from the Extended Market
Portfolio; 40,645,374 shares at an aggregate redemption price of
$1,753,619,235 from the 500 Portfolio; 9,604,301 shares at an aggregate
redemption price of $109,577,415 from the Value Portfolio; 1,805,078 shares
at an aggregate redemption price of $18,266,906 from the Growth Portfolio;
and 6,692,000 shares at an aggregate redemption price of $76,973,295 from the
Total Stock Market Portfolio.
You have instructed me to file, on behalf of the Fund, a Notice pursuant to
Rule 24f-2 of the 1940 Act, for the purpose of registering, under the 1933
Act, the combined total of 141,163,316 shares which were sold by the Fund
during the fiscal year in reliance upon Rule 24f-2 of the 1940 Act.
Based upon the foregoing information and my examination, it is my opinion
that:
1. The Fund is a validly organized and subsisting trust of the
Commonwealth of Pennsylvania authorized to issue an unlimited number of
shares, without par value, from an unlimited number of Portfolios of
shares;
2. The proposed registration of the combined total of 141,163,316 shares
of the Fund in reliance upon Rule 24f-2 of the 1940 Act is proper;
3. Such shares, which were issued for a consideration deemed by the
Board of Trustees to be consistent with the Declaration of Trust, are legally
authorized and issued, fully paid, and non-assessable; and
4. The holders of such shares have the rights provided with respect to
such holdings by the Declaration of Trust, as amended.
I hereby consent to the use of this opinion as an Exhibit to the Rule 24f-2
Notice to be filed on behalf of the Fund, covering the registration of such
shares under the 1933 Act, and to the applications and registration
statements, and amendments thereto, filed in accordance with the securities
laws of the states in which shares of the Fund which are offered. I
further consent to reference in the Prospectus of the Fund to the fact that
this opinion concerning the legality of the issue has been rendered by me.
Very truly yours,
BY: (Raymond J. Klapinsky)
RJK:fms
